Approval holders or licensees planning to implement storage systems that do not comply with the requirements of Directive 055: Storage Requirements for the Upstream Petroleum Industry (Directive 055)or Directive 055-Addendum: Interim Requirements for Aboveground Synthetically- Lined Wall Storage Systems, Updates to Liner Requirements, and Optional Diking Requirements for Single-Walled aboveground Storage Tanks (Directive 055: Addendum)must apply for an “alternative storage” approval. This approval must be in place before any construction or associated operations begin.

Section 2.5 of Directive 055 does not say what information is required in an application for alternative storage, and with the release of the Directive 055: Addendum, alternative storage applications to allow aboveground synthetically-lined wall storage systems (AWSS) on Alberta Energy Regulator (AER) licensed sites other than the site being fractured are becoming more common. Therefore, the alternative storage checklist document (linked below) includes information both for general alternative storage applications and for applications for the use of an AWSS on an alternative site.

The following contains links to relevant directives and guidance documents and outlines application procedures for getting an alternative storage approval.

Application Submission

The applicant will submit its alternative storage application through the Digital Data Submission (DDS) tool which can be found on the AER website at www.aer.ca under Systems & Tools for access. All material related to an application is stored in this system.

With submission of the application, the licensee acknowledges that all information provided is no longer confidential.

Review Process for Alternative Storage Applications

Below is a brief description of how an alternative storage application is processed once it is submitted through the Digital Data Submission (DDS) system. Effective January 1, 2012, applications can only be submitted electronically through the DDS system (Bulletin 2011-17).

All applications will be published on the Public Notice of Application page on the AER website to encourage public participation during the approval process.

Anyone who could potentially be affected by an alternative storage application may submit a statement of concern before an approval is issued. If a statement of concern is filed during the review process, the application will go through the current statement of concern application review (SOCAR) process.

Applications for alternative storage submitted through the DDS system will be picked up by an application processor and assigned to a Waste and Storage Section (W&S) signing authority.

The application processor will do an initial review to determine whether the application is administratively complete (i.e., contains the minimum information as specified in the alternative storage application checklist). The application processor will either close the application due to information deficiencies or proceed with a full technical review of the application.

The application processor will check to determine whether the applied-for well or facility site falls within the Lower Athabasca or South Saskatchewan Regional Plan areas. If the application is in one of these areas, the application will go for leadership review.

If required, the application will be referred to other AER sections or branches for specific technical review.

The review will focus on ensuring that the alternative storage request achieves an equivalent level of environmental protection and safety as is achieved by following the directive.

If required, applicants may be sent a request for additional information called a “supplemental information request” letter.

Once the application is complete and uncontested, the application processor will recommend that the application be approved, closed, or denied:

Recommendation for approval is referred to the assigned W&S signing authority. The W&S signing authority will decide to approve the application based on the application information and technical recommendation.

Recommendation for closure is referred to the assigned W&S signing authority. The W&S signing authority will decide to close the application or request additional information based on the application information and technical recommendation. If an application is closed, a licensee may re-apply without prejudice with a complete application.

Recommendation for denial is referred to the director for the final decision. If an application is denied, the applicant can file an appeal through the AER appeal process.

Once the approval is issued, the applicant will receive a link to the alternative storage approval, denial, or closure letter, which can be accessed for 30 days through the Integrated Application Registry Query. Go to www.aer.ca under Systems & Tools for access.

Application Timelines

The processing time for this application is 40 days, and the AER aims to meet this target 90 per cent of the time.